OMB control numbers

The OMB control numbers listed in 1904.45 are 1218-0176 and 1220-0045 and they map to the specific 29 CFR citations shown in the section. See 1904.45 for the official table.

• 29 CFR 1904.4–35 and 1904.39–41 and 1904.43–44 are covered by OMB Control No. 1218-0176.
• 29 CFR 1904.42 is covered by OMB Control No. 1220-0045.

This mapping appears in the regulatory text of 1904.45 (66 FR 6134, Jan. 19, 2001).

No—employers do not have a new operational obligation simply because OMB control numbers are listed; the listing documents the Office of Management and Budget approvals for OSHA's information collections under the Paperwork Reduction Act. See 1904.45.

• Employers must continue to comply with the substance of Part 1904 (for example, which cases to record and how long to retain records). See 1904 for the overall rule.
• The OMB control numbers are administrative—they show that OSHA’s collection (forms and electronic submissions) has been reviewed under the Paperwork Reduction Act and do not change the recordkeeping requirements themselves.

Yes—software-generated forms can be used if they are equivalent to the OSHA forms and meet the requirements for equivalent forms in the recordkeeping rule. See 1904.29 and the OSHA letter of interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 which explains acceptance of software-generated equivalent forms.

• An equivalent form must contain the same information, be as readable and understandable, and be completed using the same instructions as the OSHA form (1904.29(b)(4)).
• Employers may keep records on a computer system provided the system can produce equivalent forms when needed for employee access or government inspection (see the software forms letter of interpretation).

Keep copies available for employees and authorized government representatives as required by 1904.35 and 1904.40.

No—the OMB control numbers in 1904.45 identify the approved information collections; the substantive electronic submission obligations are set out in 1904.41. See also OSHA's enforcement guidance about electronic submission at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

• 1904.41 defines which establishments must submit electronic data and which forms (e.g., Form 300A) must be submitted.
• OSHA's April 16, 2024 memorandum explains enforcement timing and that OSHA is actively ensuring electronic submission compliance (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

No specific employer obligation in Part 1904 requires you to print the OMB control number on every employer copy, but the listing in 1904.45 documents OMB approval for the information collections. Employers must, however, maintain records that meet the substance and access requirements of Part 1904. See 1904 and the software-generated forms interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• If you use electronic/equivalent forms, they must provide the same information and be accessible for inspection under 1904.40.
• Including the OMB control number on an equivalent form is good practice to show the record aligns with the approved collection, but Part 1904 focuses on content, access, and retention rather than the printing of the OMB number itself.

Under 1904.45, OMB Control No. 1218-0176 covers the following 29 CFR

Under 1904.45, OMB Control No. 1220-0045 covers 29 CFR 1904.42.

• The mapping of citations to OMB control numbers is presented directly in 1904.45.

No—the obligation to retain OSHA records is set by the recordkeeping rules (for example, the retention requirements in 1904.33) and does not change because an OMB control number is listed in 1904.45.

• Keep records for the retention periods required by Part 1904 (see 1904.33).
• The OMB control number documents the PRA approval of the information collection; it does not alter record retention rules.

Yes—while OMB approval is a federal administrative requirement for information collections, State Plan authorities generally implement recordkeeping rules that are at least as effective as federal OSHA's requirements, and the OMB-approved collections in 1904.45 reflect the federal information collections tied to those rules. See 1904 for the overall Part 1904 rule.

• State Plans must have standards and enforcement programs at least as effective as federal OSHA’s; many State Plans adopt the federal recordkeeping requirements into their own rules (see general Part 1904 provisions).
• For practical compliance, follow the recordkeeping, access, and submission requirements in the applicable OSHA or State Plan rules, and note that OMB control numbers identify the federal collections associated with those rules (see 1904.45).

Yes—whether records are paper or electronic, employers must make OSHA injury and illness records available for inspection and copying by authorized government representatives and provide access to employees as required by the recordkeeping rules. See 1904.40 and the software-generated forms interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• 1904.40 requires employers to provide records to government representatives and 1904.35 covers employee access.
• The April 29, 2025 letter of interpretation confirms that computer systems and electronic formats (e.g., Excel, CSV) are acceptable provided they can produce equivalent OSHA forms when needed (https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29).

No—the listing of OMB control numbers in 1904.45 does not change who must submit data electronically; the submission obligations are set in 1904.41 and explained in OSHA's April 16, 2024 enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

• 1904.41 defines which establishments (by employee counts and industry lists) must submit Form 300A and, in some cases, Form 300 and 301.
• The enforcement memo clarifies submission deadlines and enforcement timelines for failure to submit electronically (https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16).

No—OSHA’s recordkeeping duties remain in effect while OMB renewals or updates are processed; employers must continue to comply with Part 1904 requirements. See 1904 and 1904.45.

• OMB renewals are administrative actions under the Paperwork Reduction Act; they do not suspend the regulatory obligations to record, retain, provide access to, or submit records as required by Part 1904.
• If OSHA makes procedural changes (for example, to electronic submission systems), OSHA typically issues guidance or memoranda—see the electronic submission memo at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16 for an example of agency guidance on submission enforcement.

Yes—employers may maintain equivalent OSHA records in common file formats like Excel or CSV provided the files are equivalent to OSHA forms, are readable and understandable, and can produce the required form content when needed. See 1904.29 and the software-generated forms letter at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• The April 29, 2025 interpretation specifically confirms that equivalent forms may be kept in any file format (e.g., Excel, CSV) if they meet the criteria in 1904.29(b)(4).
• Maintain the ability to produce equivalent Form 300, 300A, and 301 outputs for employee access and government inspection (1904.35 and 1904.40).

OMB approval applies to OSHA’s official information collections; internal safety logs used only for company purposes are not automatically part of those collections. However, if you rely on internal logs instead of required OSHA records, those internal logs must be equivalent to the OSHA forms when they serve as the employer’s official record under Part 1904. See 1904.29 and 1904.45.

• If your internal log is the official Part 1904 record, it must meet the equivalent-form criteria in 1904.29(b)(4).
• Records that are purely internal safety-tracking documents and not intended to substitute for OSHA-required records still should be consistent with Part 1904 to avoid gaps, and you must provide the required OSHA records to employees and inspectors per 1904.35 and 1904.40.

The OMB control mapping for Part 1904 is published in the Federal Register and the table in 1904.45 notes the citation 66 FR 6134, Jan. 19, 2001.

• See 1904.45 for the official table and the Federal Register reference.

Yes—as long as the electronic output contains the same information, is readable and understandable, follows the OSHA form instructions, and can be produced for access and inspection, the exact printed title is not required. See the equivalency rules in 1904.29 and the software-generated forms interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• 1904.29(b)(4) requires equivalent forms to have the same information and be as readable and understandable as OSHA forms.
• The April 29, 2025 interpretation explicitly allows forms in any file format (e.g., Excel, CSV) provided the equivalency criteria are satisfied (https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29).

OSHA citations focus on substantive noncompliance with Part 1904 (for example, failing to record, retain, provide access to, or submit records), not merely the absence of an OMB control number on a form. See 1904 and 1904.45.

• The core compliance obligations are set out throughout Part 1904 (e.g., recordkeeping criteria in 1904.7, access in 1904.35, and submission in 1904.41).
• If an employer’s form lacks the OMB number but otherwise meets equivalency and access requirements, enforcement would generally focus on the substantive recordkeeping failures rather than on a missing printed OMB number in isolation.

No—the OMB control numbers document approved collections under the Paperwork Reduction Act; OSHA inspectors may still request records and information that fall within the approved collections or are otherwise needed during an inspection consistent with the regulations. See 1904.45 and record access provisions like 1904.40.

• During inspections OSHA may request any records the employer is required to keep under Part 1904 and other applicable standards.
• The OMB approvals are administrative and do not limit OSHA’s statutory authority to inspect workplaces or to request records that are required by regulation.

The OMB control numbers in 1904.45 identify approved collections for Part 1904 but do not change specific rules about COVID-19 logs or reporting. OSHA has provided separate guidance on COVID-19 recordkeeping and reporting, including a temporary enforcement stay related to certain COVID-19 requirements (see https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05) and Part 1904 recordkeeping continues to apply where relevant.

• OSHA’s February 5, 2025 memorandum informs regions that OSHA will not enforce certain COVID-19 record and reporting requirements adopted under the Healthcare ETS (https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05).
• Employers must still follow Part 1904’s general recordkeeping and reporting requirements where applicable (see 1904).

The OMB control number listing documents OMB’s approval of OSHA’s recordkeeping collections, while letters of interpretation clarify how OSHA applies the Part 1904 rules in specific situations; employers must follow the Part 1904 rules and may rely on relevant OSHA interpretations for practical guidance. See 1904.45 and the software-generated forms interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• For example, the April 29, 2025 interpretation explains how software-generated forms can satisfy recordkeeping requirements (https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29).
• Use Part 1904 regulatory text for requirements and OSHA letters/ memos for clarifications on application and enforcement (see 1904).